
Dealing with changes to POPI
Once a company has implemented POPI, how does it need to be dealing with changes to POPI? To achieve a sustainable solution you have to consider future changes that could impact the level of compliance being achieved by the original initiative. This article forms part of a series of POPI Governance articles written by TOSMS, to ensure a sustainable POPI outcome for companies. The series starts here.
Being prepared for future POPI updates
There are two issues here that have to do with governance.
What happens when the government introduces changes to the legislation? Clearly this is one of the sources of change that could occur. There are two possibilities when it comes to changes to the legislation.
- The POPI Act makes allowance for industry bodies to introduce their own code of conduct where there is a need to be more specific about their practices.
- The POPI Act also gives the Minister the power to introduce changes to the legislation.
Change control built into the process
The point here, when it comes to governance, is that you have to consider the change control aspect of whatever solution your POPI compliance initiative has implemented. There will be changes within your organisation that will impact your solution and there will be external changes like those to the legislation that will have an impact.
It is critical that you build your solutions with change in mind. Know why you have made the changes to your people, processes, systems and records. Make sure there is a golden thread right back to the clauses in the legislation so that you do not have to start from scratch again when changes occur.